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Germany–UAE Tax Treaty for Dubai Real Estate — Status 2026

Is there a tax treaty between Germany and the UAE?

No. The Germany–UAE Double Taxation Agreement of 1 July 2010 was terminated by Germany with effect from 31 December 2021 and has not been applicable since. A successor agreement is not in force as of May 2026. Rental income from Dubai properties owned by German owners is therefore fully subject to the German worldwide income principle — offsetting under §34c EStG (German Income Tax Act) has no effect in the absence of UAE income tax.

Tax implications for DACH owners

Type of incomeTaxation GermanyTaxation UAE
Rental incomeFull, personal marginal tax rate0 %
Disposal < 10 yearsFull as other income (§23 EStG)0 %
Disposal > 10 yearsTax-free (§23 EStG)0 %
InheritanceGerman ErbStG (Inheritance Tax Act, worldwide income)No UAE inheritance tax

What does this mean in practice?

Rental income must be declared in Anlage V (Schedule V) of the German tax return — depreciation (AfA) on the building is possible under §7 Abs. 4 EStG (German Income Tax Act). An offsetting of foreign taxes under §34c EStG is ineffective in the absence of UAE tax liability. After expiry of the 10-year speculation period, the disposal gain from a privately held Dubai property is tax-free in Germany — economically the most important DACH lever. Anyone living in Dubai and having their tax residence there (no residence / habitual abode in Germany) is no longer subject to German unlimited tax liability — see exit taxation on relocation to Dubai.

Sources

  • Germany–UAE Double Taxation Agreement of 1 July 2010 (BGBl. II 2011 p. 538) — terminated by Germany with effect from 31.12.2021
  • BMF letter on the applicability of double taxation agreements — status 1 January 2025
  • §§ 23, 34c EStG (German Income Tax Act) — Private disposal transactions / offsetting of foreign taxes
  • UAE Federal Tax Authority — Corporate Tax Law applies to business income, not to private rental income of natural persons

Note: This article is not tax advice. Application in individual cases depends on residence, ownership structure and personal circumstances. For an individual assessment, consult a DACH tax advisor with UAE experience.

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Ali Daioub